PROGRAM TOPICS:
1.1
It is the policy of the University of Pennsylvania in coordination with the Office of Environmental Health and Radiation Safety to provide the University community with a safe and healthful environment. This policy is designed to ensure that University employees follow the appropriate procedures to prevent asbestos exposure to building occupants, visitors, maintenance personnel, and contractors.
1.2
This policy applies to all University employees involved with activities that may result in the disturbance of asbestos-containing materials.
1.3
This policy does not apply to the University of Pennsylvania Health System or University City Associates, who are covered under their own policies.
2.1
Asbestos is a fibrous silicate mineral that was commonly added to a variety of building materials to provide strength and fire/chemical resistance. Asbestos also has excellent thermal and acoustical insulating properties and was widely used in thermal and acoustical insulation products. Asbestos-containing materials (ACM) contain greater than 1% asbestos by weight as determined by polarized light microscopy (PLM).
2.2
An asbestos abatement contractor is any person, firm or corporation, who has valid licenses issued by both the Commonwealth of Pennsylvania and the City of Philadelphia Air Management Services - Asbestos Control Unit, for the purpose of removal, enclosure, or encapsulation of asbestos-containing materials.
2.3
An asbestos project inspector (API) is a person accredited by the Philadelphia Air Management Services - Asbestos Control Unit, who functions as the on-site representative of the University, performing air sampling, inspection and oversight of the asbestos abatement contractor.
2.4
An asbestos investigator is a person accredited by both the EPA and Philadelphia Air Management Services - Asbestos Control Unit, who has the sole authority to sign Asbestos Inspection Reports. The reports are required by the City of Philadelphia on all demolition projects or renovation projects in excess of $50,000 involving commercial and residential dwellings with four or more units constructed prior to 1981.
3.1
The Office of Environmental Health and Radiation Safety (EHRS) is responsible for all aspects of asbestos management and conducting hazard awareness training for all employees and selected contracted employees that may come into contact with ACM.
3.2
The University of Pennsylvania Division of Facilities Services is responsible for notifying EHRS of building renovation/demolition projects and infrastructure upgrades that may impact asbestos-containing materials and requesting Asbestos Inspection Reports for demolition and renovation projects.
3.3
Facilities Services is responsible for notifying EHRS of maintenance activities and small renovation projects that may impact asbestos-containing materials.
3.4
Supervisors are responsible for scheduling and ensuring employee attendance at annual EHRS Hazard Communication training and notifying EHRS of any damaged suspected asbestos-containing materials reported by employees.
3.5
Employees are responsible for participating in annual EHRS Hazard Communication training and reporting any damage of suspected asbestos-containing materials to supervisors.
4.1
Written Asbestos Standard Operating Procedures
The Asbestos Standard Operating Procedures outline asbestos management procedures and controls implemented by EHRS to prevent asbestos exposure to building occupants, visitors, maintenance personnel and contractors within University-owned facilities.
4.2
Emergency Procedures
Contact EHRS at (215) 898-4453 to report any situation where it is suspected that asbestos-containing materials have been damaged. EHRS will provide guidance to the caller and immediately dispatch staff to the location to assess the situation and coordinate corrective action if required.
4.3
Construction and Maintenance Activities
Facilities Services shall submit renovation and infrastructure upgrade plans to EHRS for review of impact upon ACM. An EHRS Asbestos Investigator will provide an Asbestos Inspection Report to the project manager for submittal with the City of Philadelphia building permit application. Maintenance supervisors and facility managers shall contact EHRS to coordinate asbestos abatement required for maintenance/repair work. Non-emergency asbestos abatement projects require five to ten days advance notice, depending on the quantity of ACM to be removed, for notification of Philadelphia Air Management Services - Asbestos Control Unit.
4.4
Routine Building Inspections
EHRS performs periodic inspections of buildings containing ACM to assess condition and coordinate corrective action where required.
4.5
Asbestos Abatement Activities
EHRS plans, schedules and coordinates all asbestos abatement activities with external abatement contractors. EHRS will write asbestos abatement specifications and conduct competitive bidding for applicable projects. Facilities Services will contract with the selected asbestos abatement contractor. EHRS conducts asbestos abatement project oversight including inspections and air sampling.
4.6
Training
EHRS conducts Hazard Communication training including an asbestos awareness component for all Facilities Services and Housekeeping personnel that may come in contact with ACM. The training includes: recognition of suspect ACM, health effects, regulations and regulatory exposure limits, sampling and abatement methods and a description of asbestos services provided by EHRS.
4.7
Recordkeeping
EHRS maintains all documents relating to asbestos-containing materials including air and bulk sampling data, waste disposal manifests, regulatory agency and other correspondence. EHRS also maintains an electronic database of all asbestos samples.